BRSR Awareness Is Rising in India

A Scope 3 emissions figure that cannot be broken into its component parts is not evidence of transparency. It is evidence of an unfinished disclosure. Yet that is what roughly 96% of India's Scope 3 reporters currently offer investors, assurers and regulators.

Awareness of carbon reporting has genuinely grown across Indian boardrooms in the past two years. ICRA ESG Ratings recorded a roughly 59% year-on-year rise in Scope 3 disclosure among India's top 200 listed companies, and separate research tracking BRSR reporting broadly has documented steadily expanding energy and emissions disclosure coverage. That momentum is real and deserves to be acknowledged rather than dismissed.

But awareness is not the same as depth, and Climes' 2026 research shows the two have decoupled: Scope 1 and Scope 2 disclosure at 86.8% against category-level Scope 3 disclosure of just 1.5%. Rising awareness should be treated as reason to move faster on Scope 3 depth, not as evidence the job is already underway.

SEBI's BRSR framework covers the top 1,000 listed companies by market capitalisation, with a subset of nine attributes under BRSR Core carrying a phased assurance requirement that reaches the full top 1,000 entities in FY2026-27. Scope 1 and Scope 2 emissions were specified tightly from the outset; Scope 3 has so far required only assessment rather than assurance, which is the structural reason the two numbers have moved so differently.

One view holds that this gap is reasonable. Scope 3 measurement genuinely is more complex than Scope 1 or 2, spanning fifteen GHG Protocol categories across an entire value chain, and regulators elsewhere have hesitated over the same complexity: Scope 3 disclosure was proposed and then dropped from the SEC's own climate rule on measurement-cost grounds. A company waiting for SEBI or the RBI to specify Scope 3 category reporting more precisely before investing heavily is not being negligent, it is being proportionate.

The opposing view points to the nineteen companies already reporting Scope 3 by category, several of them outside the largest IT and pharma names, as evidence that the barrier is organisational priority as much as technical difficulty. India's RBI has also already extended Scope 3 expectations into its climate-risk framework for select financial institutions, even without a finalised assurance requirement, suggesting regulatory direction is already visible for those willing to read it.

The direction of travel in Indian carbon disclosure is genuinely encouraging, but the Climes findings are a reminder that awareness and depth are different achievements, and only one of them is currently being delivered at scale.

The companies that close that gap before assurance and CBAM deadlines converge will spend the next two reporting cycles refining their numbers. The companies that wait will spend them rebuilding.